llp cliftonlarsonallen llp cliftonlarsonallen gasb update ©2014 · – podcast discussing the...

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CLAconnect.com

GASB Update May 20, 2014

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Effective Dates – Years beginning after • December 15, 2012 (June 30, 2014)

– Statement 65 – Items Previously Reported as Assets and Liabilities – Statement 66 - Technical Corrections - 2012 - an amendment of GASB

Statements No. 10 and No 62

• June 15, 2013 (June 30, 2014) – Statement 67 – Financial Reporting for Pension Plans - an amendment of

GASB Statement No. 25 – Statement 70 - Accounting and Financial Reporting for Nonexchange

Financial Guarantees

• December 15, 2013 (June 30, 2015) – Statement 69 - Government Combinations and Disposals of Government

Operations

• June 15, 2014 (June 30, 2015) – Statement 68 – Accounting and Financial Reporting for Pension Plans - an

amendment of GASB Statement No 27 – Statement 71 - Pension Transition for Contributions Made Subsequent to

Measurement Date - an amendment of GASB Statement No. 68

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GASB No. 65

Items Previously Reported as Assets and Liabilities

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Background

• Certain items previously identified as assets and liabilities are not really considered to be assets or liabilities

• The use of the concept of deferred inflows and

outflows was established to handle these items • This statement establishes those items which are

now to be recast as deferred inflows and outflows

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Deferred Inflows/Outflows

• Previously restricted only to use in hedging and Service Concession arrangements

• Deferred Outflows – A consumption of net position that is applicable to a future

accounting period (e.g. dfd loss on refunding) – Shown as a separate category below assets

• Deferred Inflows – An acquisition of net position that is applicable to a future

accounting period (e.g. Unavailable revenue in a governmental fund)

– Shown as a separate category below liabilities

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Areas of Specific Guidance • Refunding of Debt • Nonexchange transactions • Sales of Future Revenues • Debt issuance costs • Leases • Acquisition costs related to insurance activities • Lending activities • Mortgage Banking activities • Regulated Operations • Revenue recognition in governmental funds • Use of the term Deferred • Major Fund criteria - effects

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Specific Guidance

• Debt refunding – Gain or Loss from a refunding resulting in a defeasance

◊ Deferred Inflow – Gain ◊ Deferred Outflow - Loss

• Nonexchange transactions – Deferred inflows when resources are received or reported

as a receivable before: ◊ The period for which property taxes are levied ◊ The period when resources are required to be used or first

permitted

– Deferred outflows are reported for resources received before time requirements are met, but eligibility requirements have been met

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Specific Guidance (continued)

• Debt Issuance costs – Report as a period expense when incurred, no longer

amortized over the life of the debt

• Sale of Future Revenues – Transferor reports a deferred inflow for resources in both

the government-wide and fund financial statements – Only exception is found in GASB 48, para. 14 and has to do

with revenue not previously recognized due to uncertainty of inability to measure

– Intra-entity sales - recognize as deferred inflow and outflow until all revenue recognition criteria met(GASB 48, para. 15)

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• Leases – Operating lease – lessor

◊ Record initial direct costs (acquisition, legal, etc) as a period cost

– Sale/-Leaseback transaction ◊ Gain/loss on sale/leaseback should be recorded as either a

deferred inflow or outflow, as applicable

• Revenue recognition in Governmental Funds – Revenue not recognized because of availability criteria

should be reported as deferred inflows (e.g. property taxes)

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• Use of the term Deferred in GASB financial statements – Limited only to use in connection with “Deferred Inflows”

and “Deferred Outflows”

• Major Fund Criteria – Utilize deferred Outflows as part of assets and deferred

inflows as part of liabilities in the calculations in determining major funds

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11

GASB No. 66 an amendment of GASB No. 10 and 62

Technical Corrections – 2012

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Fixed…

• GASB No. 54, removed the limitation on using general fund or internal service fund for risk financing activities

• GASB No. 62, 13, and 48. Clarified language on issues related to: – Operating leases – Recognition of premium or discount on purchase of loans – Servicing fees for receivables that have been sold

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GASB No. 67

Financial Reporting for Pension Plans

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Scope and Applicability

• Replaces previous guidance under GASB No. 25, Financial Reporting for Defined Pension Plans and Note Disclosures

• Establishes financial reporting standards for pension plans administered through trusts in which: – Contributions to the plans and related earnings are irrevocable – Plan assets are dedicated to providing pensions to plan members in

accordance with benefit terms – Plan assets are legally protected from creditors of employers,

nonemployer contributing entities and plan administrators

• Applicable for defined benefit plans and defined contribution plans

• Does not include OPEB plans

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Defined Benefit Pension Plans

• Recognition, measurement and presentation of the financial statement amounts generally similar to current guidance – Incorporates deferred outflows of resources and deferred

inflows of resources, where applicable

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Defined Benefit Pension Plans (continued)

Required Financial Statements • Statement of Fiduciary Net Position

– Assets + Dfd Outflows – Liabilities – Dfd Inflows = Fiduciary Net Position

• Statement of Changes in Fiduciary Net Position

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• Notes to the Financial Statements: – Plan description – Allocated insurance contracts excluded from plan assets – Plan investments, including investment policy, determination of

fair value, annual money-weighted rate of return and identification of investments that represent 5% or more of plan net position

– Receivables - terms of any long term contracts for contributions to the plan

– Deferred retirement option program (DROP) balances – Policy for reserves of plan net position

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• Notes to the Financial Statements: – Components of the net pension liability, including

◊ Total pension liability ◊ Pension plan’s fiduciary net position ◊ Net pension liability ◊ Pension plan’s fiduciary net position as a percentage of total

pension liability – Significant assumptions used to measure the total pension

liability – Date of actuarial valuation and if applicable, disclosure that roll

forward procedures were used to roll forward the total pension liability from the actuarial valuation date to the plan’s fiscal year end

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Defined Benefit Pension Plans (continued) • Required Supplementary Information:

– 10 year schedule of ◊ Changes in net pension liability ◊ Net pension liability ◊ Contributions ◊ Annual money –weighted rate of return

– Encouraged to present all years retroactively in implementation year ◊ If retroactive information is not available for all 10 years, only include those

years where information is available in transition year and until 10 yrs of such information is available

• Notes to the Required Schedules: – Significant methods and assumptions used in calculating the

actuarially determined contributions

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LLP Schedule of Changes in Net Pension Liability

Last 10 Fiscal Years Schedules of Required Supplementary Information SCHEDULE OF CHANGES IN THE SCHOOL DISTRICTS’

NET PENSION LIABILITY Last 10 Fiscal Years

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Schedule of Net Pension Liability Last 10 Fiscal Years

SCHEDULE OF THE SCHOOL DISTRICTS’ NET PENSION LIABILITY Last 10 Fiscal Years

(Dollar amounts in thousands)

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Schedule of Contributions Last 10 Fiscal Years

SCHEDULE OF SCHOOL DISTRICTS’ CONTRIBUTIONS Last 10 Fiscal Years

(Dollar amounts in thousands)

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Schedule of Investment Returns Last 10 Fiscal Years

SCHEDULE OF INVESTMENT RETURNS Last 10 Fiscal Years

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• Net Pension Liability – Total pension liability, net of plan’s fiduciary net position

• Measurement of Total Pension Liability – Timing and frequency of actuarial valuations

◊ As of plan’s most recent fiscal year end or ◊ The use of update procedures to roll forward to plan’s most recent fiscal

year end from actuarial valuation ◊ Actuarial valuation date can be no more than 24 months prior to plan’s

fiscal year end

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• Measurement of Total Pension Liability – Discount rate

◊ Long term expected rate of return on investments that are expected to be used to finance payment of benefits, to the extent that net position is sufficient to make projected benefits and assets are invested using a strategy to achieve that return,

◊ Yield or index rate for 20 yr, tax exempt general obligation municipal bonds with an average rating of AA/Aa or higher to the extent the conditions used for the long term expected rate of return are not met.

– Actuarial cost method ◊ Entry age actuarial cost method should be used to attribute the

actuarial present value of projected benefit payments to periods

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Defined Contribution Plans

• Footnote disclosures should include: – Identification of the pension plan as a defined contribution

pension plan – Classes of members covered – Number of plan members – Participating employers for multiple-employer plans – Nonemployer contributing entities, if applicable – The authority under which the plan is established or may

be amended.

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Additional Resources

• GASB Toolkit (available at the GASB website)

– Guide to Implementation of GASB Statement 67 on Financial Reporting for Pension Plans

– Podcast discussing the types of pension plans affected by Statement 67 and most significant changes

– Article on the key implementation issues – Summary and Full Text of Statement 67

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GASB No. 70

Accounting and Financial Reporting for Nonexchange Financial Guarantees

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Background

• Investors are looking for more credit enhancements and assurances on obligations – Minimize the possibility of nonpayment

• Government often provide guarantees and receive guarantees for free – Belief nonpayment is not likely

• Currently, a liability is recorded when – It is probable the government will be required to pay and

amount can be reasonability estimated

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• Government provides a financial guarantee as a nonexchange transaction

• Government receives a financial guarantee as a nonexchange transaction

• Key considerations – Three legally separate entities (component units qualify) – Not deemed guarantees for this statement

◊ Withholding or garnishing revenues ◊ Pledges of future revenues ◊ Joint-and-several obligations

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Three Legally Separate Entities

Obligation Holder

Issuer Guarantor

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Government as the Grantor

• Assess the issuer’s ability to pay using qualitative factors

• If the government is more likely than not required to pay the issuer’s debt, then “book it” – More than 50% likelihood

• Book - – The discounted present value of expected cash flows as

the result of the guarantee, or – If cash flows are within a range, the discounted present

value of the minimum expected cash flows (low part of the range)

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Qualitative Factors

• Bankruptcy or financial reorganizations • Breach of debt contract

– Covenants – Coverage ratios – Default

• Other financial difficulty indicators – Loss of major revenue source – Debt holder concessions – Using earmarked funding to pay debt

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“Book It”

• Journal entry

– DR: Expense/Expenditures – CR: Nonexchange Financial Guarantee

• Government-wide Financial Statements, and • Fund Financial Statement to the extent the liability is

normally expected to be liquidated with expendable available financial resources.

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Government as a Guarantor to a Group

• You could analyze individually, or • You could analyze as a group using qualitative factor

of the group - – Historical trends – Economic factors – Etc.

• May book a liability similar to an allowance on bad debt, historical trends

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Practical Timing Issue

• The process should be ongoing and the books and records should be adjusted when the government becomes more likely than not to pay the debt of the issuer.

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Disclosures

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Government as Issuer

• Footnote disclosure explaining the guarantee • If the government is required to repay the guarantor,

then the liability should be reclassified as a liability to guarantor when the guarantor begins to pay the debt.

• If the government is legally released from the debt, a revenue is recognized for guarantor’s assumption of the liability.

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Disclosure

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Intra-Entity

• Primary government guarantees a blended component unit’s debt

• Blended component unit guarantees a primary government's debt

• Blended component unit guarantees another blended component unit

• A receivable should be booked in the amount of the liability booked by the guarantor

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GASB No. 68

Accounting and Financial Reporting for Pension Plans

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Background

• Part of the effort which goes back to GASB 34 to make government statements more usable, comparable and on par with the corporate world – Investors understand full accrual accounting and get

confused with multiple levels of government reporting

• Gives a better perspective as to both financial position and financial condition

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• Applies to: – Employers in single-employer and agent multiple-

employer defined benefit plans – Employers in cost-sharing plans – Special funding situations

◊ One government makes payments on behalf of another

– Employers in defined contribution plans

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Defined Benefit Pensions

• Employer liability – Current: Difference between the annual required

contribution (ARC) and actual contributions = Net pension obligation ◊ Only record a liability if required funding not made

– New: Difference between the total pension liability and the fiduciary net position = Net pension liability ◊ Record net liability of the governmental entity

– Measured as of a date no earlier than the end of the employer’s prior fiscal year (measurement date)

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Defined Benefit Plans (continued)

• Changes in the pension liability – – Service cost, interest on the pension liability and changes

in benefit terms ◊ Recorded as pension expense immediately

– Changes in economic and demographic assumptions and differences between economic and demographic assumptions and actual experience ◊ Amortized over a closed period equal to the average remaining

service period for plan members ◊ Current portion recorded as pension expense ◊ Remaining portion recorded as deferred outflows or deferred

inflows of resources

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• Changes in the pension liability (continued) – – Differences between expected and actual rates of

investment returns ◊ Amortized over a closed 5 year period (including current period) ◊ Current portion recorded as pension expense ◊ Remaining portion recorded as deferred outflows or deferred

inflows of resources

• Employer contributions made subsequent to the measurement date of the net pension liability are recorded as deferred outflows of resources

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• Actuarial valuations – Required at least every two years – Total pension liability should be determined by

◊ An actuarial valuation as of the measurement date which must be within 1 year and 1 day of the report date or

◊ The use of update procedures to roll forward from the actuarial valuation to the measurement date no more than 30 months and 1 day before employers year end

– Entry age method only ◊ Consistency –multiple methods no longer accepted ◊ No tie to actuarial method used for funding ◊ Service cost determined as a percentage of pay

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LLP Timing of Measurement of Total Pension Liability

48

June 2014

Plan Prior

Year-End

Plan Current

Year-End

December 2014

June 2015

December 2015

Pension Expense (measurement period)

Deferred Outflows of Resources

Employer Current

Year-End

Employer Prior

Year-End

Measurement date will most likely correspond to year-end of plan. Employer contributions made directly by the employer subsequent to the measurement date of

the net pension liability and before the end of the employer’s fiscal year should be recognized as a deferred outflow of resources.

Measurement Date

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LLP Example – Impact of Using Prior Year Measurement Date

49

June 2013

Plan Year-End

June 2014

Pension Expense (measurement period)

Deferred Outflows of Resources

Employer Current

Year-End

Employer Prior

Year-End

Measurement Date

Plan Year-End

June 2015

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LLP Example – Impact of Using Current Year Measurement Date

50

June 2013

Plan Year-End

Plan Year-End

June 2014

Pension Expense (measurement

period)

Employer Current

Year-End

Employer Prior

Year-End

Measurement Date

Plan Year-End

June 2015

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Projection of Benefit Payments

• Projections Include: – Automatic cost of living adjustments (COLAs) and other

automatic retroactive benefit changes – Ad hoc COLAs and ad hoc retroactive benefit changes –

substantively automatic – Projected future salary increases – if benefit formula is

based on future levels – Projected future service credits (when determining

probability of eligibility for benefits and when formula is based on years of service)

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New Blended Discount Rate

• Single rate reflective of: – Long-term expected rate of return to extent plan net

position for specified source is: ◊ Projected sufficient to make benefit payments ◊ Expected to be invested using long-term investment strategy

• Otherwise, index rate for a tax-exempt 20-year GO rated AA/Aa (or equivalent) or higher

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Example Scenario- Discount Rate

• Current Situation – 8% discount rate, same as historical rate of return – 75% funded plan – 20 year GO rate is 4%

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Example Scenario- Discount Rate (cont’d)

New Calculation: Blended rate

Calculation Step Example Funded % X Historical Rate of Return

75% X 8% 6%

Unfunded % X Tax Exempt 20yr Rate

25% X 4% 1%

Blended Discount Rate 6% + 1% = 7%

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Projected Beginning

Fiduciary Net Position

(b)

Projected Benefit

Payments(c)

"Funded" Portion of

Benefit Payments

(d)

"Unfunded" Portion of

Benefit Payments

(e)

Present Value of "Funded" Benefit

Payments(f) = (d) ÷ (1 + 7.5%)(a)

Present Value of "Unfunded" Benefit

Payments(g) = (e) ÷ (1 + 4%)(a)

Present Value of Benefit Payments Using the Single Discount Rate

(h) = (c) ÷ (1 + 5.29%)(a)

1,431,956$ 109,951$ 109,951$ $ - 102,280$ $ - 104,427$

1,500,197 116,500 116,500 - 100,811 - 105,088

1,565,686 123,749 123,749 - 99,613 - 106,019

1,628,547 131,690 131,690 - 98,610 - 107,154

1,687,890 140,229 140,229 - 97,678 - 108,370

1,742,722 149,168 149,168 - 96,655 - 109,487

1,792,194 158,466 158,466 - 95,516 - 110,468

1,835,463 168,332 168,332 - 94,384 - 111,450

1,871,402 178,591 178,591 - 93,150 - 112,302

1,898,930 189,069 189,069 - 91,735 - 112,918

547,880 322,779 322,779 - 49,236 - 84,503

316,985 326,326 - 326,326 - 113,175 81,140

64,800 328,997 - 328,997 - 109,713 77,694

- 330,678 - 330,678 - 106,032 74,168

- 331,266 - 331,266 - 102,135 70,567

- 1 - 1 - - -

- - - - - - -2,109,333$ + 1,724,534$ = 3,833,867$

10

26

27

28

29

30

96

97Total

Projected Benefit Payments Actuarial Present Values of Projected Benefit Payments

Year(a)

1

2

3

4

5

6

7

8

9

Discount rate calculation

55

The sum of the present values of the two benefit payment streams is

calculated.

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Cost Sharing Plans • Cost Sharing Employers

– Current: ◊ Liability recorded only if the actual employer contribution is less than

annual required contribution ◊ Expense is equal to annual required contribution

– New: ◊ Liability is equal to the employers’ proportionate share of the total net

pension liability of all participating employers • Will now allow readers to determine overall liabilities currently not easily

determinable • More pressure to adequately fund

◊ Expense is equal to the employer’s proportionate share of the pension expense of all participating employers

◊ Both liability and expense are reported as of the date reported by the plan – No need to adjust/rollforward to actual report date of the government

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Cost Sharing Plans (continued)

• Employer’s recognize their proportionate share of collective: – Net pension liability – Pension expense – Deferred outflows of resources – Deferred inflows of resources

• This will provide audit challenges

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Special Funding Situations

• Nonemployer entity legally responsible for making contributions directly to a pension plan for the employees of another entity and either: – The amount of contributions for which the nonemployer

entity legally is responsible is not dependent upon one or more events unrelated to pensions

or – The nonemployer is the only entity with a legal obligation

to make contributions directly to the pension plan

• Nonemployer contributor accounting patterned on accounting for employers in cost-sharing plans

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Defined Contribution Plans

• No significant changes

• Expense – Amount of contributions (employee and employer) to the employee accounts, net of forfeited amounts

• Liability – Difference between the amount of the expense recorded and amount paid to the plan

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Note Disclosures

• Description of the Plan

• Assumptions Used to Measure Total Pension Liability

• Brief Description of Changes in Benefit Terms and Assumptions that Affect Measurement of Total Pension Liability

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Required Supplementary Information – Single Employer Plan

SCHEDULE OF CHANGES IN THE COUNTY’S NET PENSION LIABILITY AND RELATED RATIOS

Last 10 Fiscal Years

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Required Supplementary Information – Single Employer Plan (continued)

SCHEDULE OF COUNTY CONTRIBUTIONS Last 10 Fiscal Years

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Required Supplementary Information – Cost-Sharing Employer Plan

SCHEDULE OF THE DISTRICT’S PROPORTIONATE SHARE OF THE NET PENSION LIABILITY Teachers Pension Plan

Last 10 Fiscal Years*

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Required Supplementary Information – Cost-Sharing Employer Plan (continued)

SCHEDULE OF DISTRICT CONTRIBUTIONS Teachers Pension Plan

Last 10 Fiscal Years

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Required Supplementary Information – Special Funding Situation

SCHEDULE OF THE DISTRICT’S PROPORTIONATE SHARE OF THE NET PENSION LIABILITY Teachers Pension Plan


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Required Supplementary Information – Special Funding Situation (Continued)

SCHEDULE OF THE DISTRICT CONTRIBUTIONS Teachers Pension Plan


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Required Supplementary Information – Special Funding Situation: Nonemployer Contributing Entity

SCHEDULE OF THE STATE’S PROPORTIONATE SHARE OF THE NET PENSION LIABILITY Teachers Pension Plan


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Required Supplementary Information – Special Funding Situation: Nonemployer Contributing Entity (continued)

SCHEDULE OF THE STATE CONTRIBUTIONS Teachers Pension Plan


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Additional Guidance

• AICPA White Paper: Governmental Employer Participation in Cost-Sharing Multiple-Employer Plans: Issues Related to Information for Employer Reporting – Provides guidance on employer challenges related to

recognizing proportionate share of collective pension amounts and related auditor issues

– Recommends cost-sharing plans calculate each employer’s allocation percentage and collective pension amounts ◊ Prepare a Schedule of Employer Contributions and related Notes to the

Schedule ◊ Plan engage its auditor to form an opinion on the schedule in accordance

with AU-C section 805, Special Considerations – Audits of Single Financial Statements and Specific Elements, Accounts, or Items of a Financial Statement

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Additional Guidance (continued)

• GASB Toolkit (available at the GASB website)

– Guide to Implementation of GASB Statement 68 on Accounting and Financial Reporting for Pensions

– Videos outlining key issues, discussing stakeholder outreach, and top implementation issues

– Podcasts discussing the most significant changes to accounting and financial reporting for pensions

– Background documents and fact sheets – A “Setting the Record Straight” document addressing

common misperceptions about the new pension standards

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Background

• APB Opinion No. 16, Business Combinations – Pooling of interests – Purchase method – Superseded by FASB No. 141 – Business Combinations

◊ Did not apply to nonprofit organizations ◊ Eliminated pooling of interests

• FASB No. 164 – NFP Entities: Mergers and Acquisitions

• Governments used superseded guidance in APB Opinion No. 16

• Needed some GAAP for governments

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• Establishes standards for government combinations and disposals of government operations – Government merger – Government acquisition – Transfer of operations

• Transactions – Combinations of legally separate entities

◊ NFP, For profit, government (new or continuing government is formed)

– Mergers and acquisition of activities less than the entire legally separate entity

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Scope and Applicability (cont.)

– “Operations” – integrated set of activities conducted and managed for the purpose of providing identifiable services with associated assets and liabilities ◊ Examples: fire department, golf course, parking garage, etc.

• Disposal of “operations” • Statement does not apply to:

– Assets and liabilities not considered an operation ◊ Line items

– Organizations that remain legally separate (GASB 14) – Equity interests in an organization (GASB 14)

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Definitions

• Government merger – combination of legally separate entities without significant consideration exchanged

• Transfer of operations – combination of operations without significant consideration

• Government acquisition - combination of legally separate entities or operations with significant consideration exchanged

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Consideration

• Assets

• Assumption of liabilities

• Contingent assets

• NOT assumption of negative net position

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Merger

• Government merger – combination of legally separate entities without significant consideration exchanged

• Two or more are now one – Pooled, but don’t use the word pooled. – No revaluations – Test for impairment – Eliminate transactions between the parties

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Transfer

• Transfer of operations – combination of operations without significant consideration

• “Pooling” with an equity modification – Net position transferred is a special item

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Acquisition

• Government acquisition - combination of legally separate entities or operations with significant consideration exchanged

• Purchase method (sort of) – Intangible asset (i.e. goodwill-deferred outflow)

• Detailed measurement rules

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Measurement Rules

• Acquisition date – Control of assets – Obligated for the liabilities

• Acquisition value – market-based entry price – Price that would be paid for acquiring similar assets, having similar

service capacity or discharging the liabilities assumed

• Exceptions – OPEB, pensions, compensated absences – Landfill, pollution remediation – Investments – Deferred inflows and outflows

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GASB No. 71

Pension Transition for Contributions Made Subsequent to the Measurement Date

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Background

• GASB 68 requires: – Recognition of a net pension liability measured as of a

date no earlier than the end of its prior fiscal year ◊ If a contribution is made between the measurement date and the

end of the reporting period, its recognized as a deferred outflow of resources

– Recognition of deferred outflows and inflows of resources for other pension-related events ◊ Differences arising between expected and actual experience in

relation to economic and/or demographic factors ◊ Effects of changes of assumptions about future economic or

demographic factors ◊ Differences between projected and actual investment earnings

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Background (continued)

• At transition, if it’s not practical to determine the amounts of all deferred inflows and outflows of resources related to pensions, no beginning balances for deferred inflows and outflows be reported

• Potential for significant misstatement of beginning net position and subsequent expense in accrual based statements if the employer does not recognize its contributions made after the measurement date of the beginning net pension liability as deferred outflows of resources at transition

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Summary

• When it’s not practical to determine all amounts of deferred inflows and outflows of resources related to pensions, GASB 71 states:

◊ Employers should recognize a beginning deferred outflow of resources for pension contributions, if any made subsequent to the measurement date of the beginning net pension liability

◊ No beginning balances for other deferred inflows and outflows of resources related to pensions should be recognized

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CLAconnect.com

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linkedin.com/company/ cliftonlarsonallen

Dennis J. Osuch, CPA Principal, State and Local Government [email protected] Brian Lehrich Associate, State and Local Government [email protected]

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